What is bottled water, and what is not?

In South Africa, bottled water (or packaged water, as it is referred to in the legislation – the public and bottlers often use these terms interchangeably) is regarded as a food product and as such is governed by the Department of Health.

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Briefly, the Department of Health views waters as follows:

Tap water as drinking water and needing to comply with public water supply regulations
Bulk water transported in tankers to distribute to rural or urban areas as public water supply, and not within the scope of packaged water legislation
Re-filling into the consumer’s own containers as drinking water, not within the scope of packaged water legislation
Bottled water as packaged water, and needing to comply with packaged water legislation
Bench-top treated waters and shop-floor treated waters bottled on site as packaged water, and needing to comply with packaged water legislation
Bulk water in large bottles for office coolers as packaged water, and needing to comply with packaged water legislation

Tap water (or drinking water, as it is referred to in the legislation) and bottled/packaged water cannot be compared in terms of legislated category and quality because they need to comply with different standards and legislation.

According to this the legislation governing packaged water, there are three main types of bottled water:

Natural Water
Water Defined by Origin
Prepared Water

Natural Water (for example natural mineral water, natural spring water) is water of certain composition, obtained directly from a natural or drilled underground source, bottled near the source under hygienic conditions. Permitted treatment includes separation from unstable constituents (such as iron manganese, sulphur) by means of filtration or decantation, without modifying the original mineral content of the water.

Approximately 70% of all bottled water in South Africa is natural water.

Water Defined by Origin, which includes spring and mineral water, is water from a specific environmental source, such as a spring, without passing through a community water system. Treatment may not alter the essential physical-chemical characteristics or compromise the safety of the packaged water. Permissible treatments include:

Remove or eliminate dissolved gasses and unstable constituents (such as compounds containing iron, manganese, sulphur, excess carbonates).
Reduction or separation of elements originally present in excess of maximum limits stipulated in SANBWA’s standards without modifying the general mineral composition of the water.
A single or combination of antimicrobial treatments such as 0.2-micron filtration, heat sterilisation, UV treatment or ozonation
Addition of air, oxygen, ozone or CO2.

Due to antimicrobial treatment required for water exposed to the environment, the water in this category may not be called ‘natural’ although it originates from a natural environmental source.

Spring water is bottled water sourced from an underground formation from which water flows naturally to the surface of the earth, and which is collected from the spring or from a borehole tapping the underground formation, and which may be classified as a Natural Water (if collected by means of a borehole) or as Water Defined by Origin (an antimicrobial treatment is allowed).

Mineral water is bottled water, obtained direct from subterranean water-bearing strata, which contains mineral salts in various proportions, characterised by its mineral content of constant composition and temperature, taking into account natural cycles and fluctuations. It may be classified as a Natural Water or as Water Defined by Origin (if an antimicrobial treatment is applied).

Approximately 20% of all bottled water in South Africa is Water Defined by Origin.

Prepared Water is water that has undergone antimicrobial treatment as well as treatment that alters the original physical or chemical properties of the water. Water bottled from an underground or a municipal source, that has undergone both reverse osmosis and ozonation as a minimum, would be categorised as Prepared Water. Permissible treatments include:

Any antimicrobial treatment. UV not allowed as a sole antimicrobial treatment.
Treatments to remove or reduce chemical substances above maximum limits including treatments that modify the physiochemical composition and characteristics of the original water source – such as reverse osmosis.
Remineralisation. The prepared packaged water must meet requirements for bottled water stipulated in SANBWA’s standards.

Approximately 10% of all bottled water in South Africa is Prepared Water. It is safe water that is used for drinking.

Consumer health is put at risk by those who don’t comply to legislation. This includes to fly-by-night operators, as well as restaurants, hotels and caterers using counter-top filtration systems to package water into Grolsch-type glass bottles and the retailers that package water in their stores, often using ozonators or filtering systems.

If the shop or restaurant fills the water in containers and closes them before offering them for sale, it is regarded as packaged water by the Department of Health and should comply with the same legislation that bottled water manufacturers comply with.

If the consumer brings his or her own container and refills in the retailer’s store, it is regarded as drinking water and must comply with drinking/municipal water legislation only.

The critical health and quality issue is that retailers and restaurants do not only refill, they bottle stock to sell in the shop or restaurant like packaged water. This practise does not comply with legislation and both drinking and packaged water is sold incorrectly under the same brand name, thereby misleading the consumer.

This water is seldom bottled in specialised facilities such as ‘clean rooms’, nor does it go through any controls and testing procedures. This means it can be produced at a lower price than SANBWA-member bottled water, but the quality and bacterial stability cannot be compared.

In addition, a beverage bottle – such as the Grolsch-type glass bottle often used in restaurants – is not designed to facilitate adequate cleaning and hygienic re-filling for the food category.